In Dussault v. RRE Coach Lantern Holdings, LLC, Nicole Dussault filed a complaint with the Maine Humane Rights commission (Commission) alleging a claim of unlawful housing discrimination. Dussault asserted that when RRE Coach Lantern Holdings, LLC and Resource Real Estate Management, Inc. (collectively, Coach Lantern) refused to include a federal Section 8 Housing Choice Voucher Program tenancy addendum in her apartment lease, Coach Lantern discriminated against her because her status as a public assistance recipient. Following an investigation and hearing, the Commission unanimously concluded that there were reasonable grounds for a belief of unlawful housing discrimination. Dussault then brought suit in Cumberland County Superior Court. Dussault alleged that Coach Lantern’s policy of not including a Section 8 tenancy addendum in its standard lease constituted housing discrimination in violation of the Maine Human Rights Act (MHRA). Specifically, Dussault asserted three theories of discrimination under the Act: direct evidence, disparate treatment, and disparate impact. The Superior Court granted Coach Lantern’s motion for summary judgment, denied Dussault’s cross-motion for summary judgment, and ultimately ruled for Coach Lantern on all three theories of discrimination.
Ari B. Solotoff,
Dussault v. RRE Coach Lantern Holdings, LLC: Does Maine Recognize Disparate Impact Liability for Claims of Housing Discrimination Brought by Section 8 Recipients under Maine Law?,
Me. L. Rev.
Available at: http://digitalcommons.mainelaw.maine.edu/mlr/vol67/iss1/8